Field Day, the licensing consultation has begun

The Field day & Mighty Hoopla licence application was submitted yesterday . There will be a 28 day statutory consultation period during which you can comment on the application.

This is advertised by way of blue notices around the park and an advertisement in the local press as well as on the Lambeth Council Website. The website also has details of how to comment on an application here.

All objections/supporting comments are put before the Licensing Committee; they have to to address Lambeth’s Licensing objectives:

1. Prevention of crime and disorder

2. Public safety

3. Prevention of public nuisance

4. Protection of children from harm; this largely relates to licensing of “adult” entertainment 

Applicants will see the objections and will be allowed to answer them. If you wish to see the full details of the licence application, please contact us for a copy.

The map below shows the extent of the Field Day and Mighty Hoopla venue within Brockwell Park

Field Day - Licensable Area copy

 

Biodiversity and major events

Comments to Lambeth from Helen Firmiger on the effects of events on biodiversity and on Lambeth’s responsibilities

RE Brockwell Park Events Strategy 2018

I am writing to express concern over Lambeth’s events strategy for Brockwell Park, and to point out certain legal and statutory issues regarding biodiversity, which appear to have been omitted in putting together this strategy and current proposals. If I have missed any separate information which covers the points below, I would be grateful to see a copy.

1) Biodiversity Duty As you will be aware there is a duty on local authorities and other public bodies to take account of biodiversity in your plans and services, as specified in Section 40 of the Natural Environment and Rural Communities Act 2006. ‘Public authorities should consider how wildlife or land may be affected in all the decisions that they make.’ You will also be aware that Brockwell Park is a Site of Importance for Nature Conservation (SINC) Borough Grade 1 in your local plan. The entire park is designated and the Biodiversity duty unquestionably applies. Further information on the Biodiversity duty is here: Unfortunately, I cannot see any place that Lambeth has taken account of this, there appears to be no mention of ecology in your Event Strategy for parks, or in the current proposals for Brockwell Park.

2) Lambeth’s own commitment to Borough SINCs. This is how Lambeth describes Sites of Borough Importance for Nature Conservation on its planning policy website. ‘These are sites which are important on a borough perspective in the same way as the Metropolitan sites are important to the whole of London. Although sites of similar quality may be found elsewhere in London, damage to these sites would mean a significant loss to the borough. As with Metropolitan sites, while protection is important, management of borough sites should usually allow and encourage their enjoyment by people and their use for education. Further information on SINCs can be found in our Local Plan, in particular policy EN1.’ Lambeth appears to be proposing two events which would cause damage to Brockwell Park, hence in its own words initiating a significant loss to the borough. Even more significantly, the proposals being considered deny access to a substantial portion of this site, an even more significant loss to the borough.

3) Policy issues around access: education, mental health, equality   To focus on a line from Lambeth’s summary of the relevance of a Borough SINC (full paragraph above): ‘…while protection is important, management of borough sites should usually allow and encourage their enjoyment by people and their use for education.’

3a) These sites should clearly be open to the public and schools. It seems ludicrous that Lambeth itself might then consider denying its residents access to large parts of this valuable site, for some of the most important months of the year.

3b) Lambeth will be aware of its own issues around mental health. It is now widely recognised across public health bodies that access to quality green space provides positive benefits to mental health, and also fights obesity, for residents. Public Health England recognises the need for protection of green space, for example gives an example intervention in its Prevention Concordat for Better Mental Health: Prevention planning resource for local areas: ‘Create and protect green spaces within neighbourhoods to generate better physical and mental health outcomes for individuals and communities. Accessing green spaces can not only encourage physical activity but other benefits such as greater community cohesion and less social isolation; opportunities for meaningful volunteering experiences;’

3c) Furthermore there is an equality issue here. Research has repeatedly shown that urban green spaces are particularly important to black and ethnic minority residents, who in many cases, find it harder to access nature in the countryside. The Design Council, for example investigated this issue in Urban Green Nation and Community Green. In summary research revealed: ‘in areas where more than 40 per cent of residents are black or minority ethnic there is 11 times less green space than in areas where residents are largely white. And the spaces they do have are likely to be of a poorer quality. Although where you live and the services you receive is intimately related to income, our research found a difference, by ethnicity, that was over and above what would be expected for level of income alone.’

‘Providing good-quality green space is a hugely effective way to tackle these inequalities. Green space has been proven to reduce the impact of deprivation, deliver better health and wellbeing and create a strong community. The simple presence of green space is related to a reduced risk of serious problems like depression and lung disease. Living close to green space reduces mortality, which can help reduce the significant gap in life expectancy between rich and poor.’

4) Legal issues relevant to species present

4a) Bat species recorded include Pippistrelle, Noctule, Daubentons, Leislers, and Serotonine, all of which are from protected by law from disturbance. 4b) Bird species recorded include House Sparrow, Nuthatch, Great-spotted Woodpecker, Green Woodpecker, Goldcrest, Common Whitethroat, Blackcap, Chiffchaff, Greenfinch, Chaffinch, Whinchat, Common Redstart, Redwing, Meadow Pipit, Peregrine Falcon, Kestrel, Hobby, Sparrowhawk, Swift, Swallow, House Martin. All of these are protected from disturbance during their nesting season (peak period February to July), legally protected until August. According to Government guidance, ‘These activities can affect wild birds, particularly during breeding season: • trimming or cutting trees, bushes, hedges and rough vegetation • renovating, converting or demolishing a building • creating disturbance, eg noise, lighting and vibration’

5) Other species of concern: While not legally protected, the Council has the aforementioned Biodiversity duty to pay regard to all wildlife here, which contribute in its own way to our mental health and our children’s development. Habitats here include: • Grasslands and meadows, where a range of grasshoppers, butterflies and other invertebrates are found in late spring and summer. These grasslands, as seen during the Lambeth Country Show, are at significant risk of trampling by event visitors, by event traffic, or potentially, through increased pressure from displaced park visitors by the fencing off of a significant patch of the site. • Mature trees, which should be protected • Ponds and lakes, containing sensitive waterfowl, invertebrates and fish. • Shrubberry and hedges, significant for small birds, and dominant along the Herne Hill side of the park The grasslands would certainly be affected by any increase in festivals, particularly in summer. It is less clear whether other areas would be affected by large festivals, however they should still be fully surveyed and damage avoided by Lambeth before taking any action.

5) Capacity and Seasonality We already have one major event regularly held in this nature site of Borough importance. The Lambeth Country Show, while causing some damage, is to a certain extent appropriate for this site, this is because: • It promotes access to nature: It gives all our city children and adults a rare chance to encounter farm animals, horses, horticulture, crazy plants, wildlife charities, vegetable personalities, falconry and bee hives. • It is freely open to all • It is held relatively late in the year, in July. This allows a certain range of wildlife to get through the active spring element of their lifecycle, including birds fledging, and grasshoppers hatching and mating. It was previously held in August, which is to be honest, a better time for it. • It does not involve any disturbance at night.

6) Recommendations: These are complex issues and I am sure you will discuss these with your own professionals and take legal advice on how best to follow your duties and avoid breaking the law. If any future festivals are to be held in the park, these in themselves should follow the principles above.

• The festival should be late in the year (after mid July).

• It should promote nature

• It should be freely open to all.

• It should not involve disturbance at night. In planning and assessing event applications, the Council should take account of the following:

• Ecology should be considered, surveyed and steps set out to protect it

• Particular consideration should be given to the fragile grasslands.

• Legal issues around birds and bats should be considered

• Cumulative impacts of more than one event should be assessed • Impact on local communities and their health should be assessed

• Equality issues around impact on mental health should be assessed.

Lambeth should celebrate Brockwell Park as a significant natural asset for all communities. This should be a starting point in any event strategy for the park. Until these are dealt with in a sensible and transparent manner, I strongly object to any plans to increase festivals in the park, and object to the plans for Lovebox and Field Day.

Lambeth’s consultation process explained….

This explanation of the process for applications to hold events in Lambeth’s parks was received from Lee Fiorentino, Director of Lambeth Events:

As per the Councils events policy outlined in the Events Guide, the event application process is set out in 4 stages which all event applicants must meet in order to be granted approval to move to each stage and then to the final stage 4 permission to use Council land for an event.

All applications are added on a weekly basis to the Events Programme Calendar spread sheet which is then emailed weekly to Park Management Advisory Committees, Friends of Parks, key external stakeholders, Council staff, ward councillors and local MPs. This gives interested parties regular weekly opportunities to request further information from the events team should they require it on a particular proposed event listed. All event applications can be approved or rejected at any stage of the event application process and so not permit to proceed any further through the process.

Detailed below sets out the event application process and timelines which is set out in out Events Guide for your information.

Events Application Process
• Stage 1 – Operational and Technical Assessment of Event Applications. Once submitted to us these can take up to 10 working days or even 4 weeks for larger events to process depending the level of technical and operational assessment needed by the events team to approve it to proceed to Stage 2 of the event application process.
• Stage 2 – Safety Assessment by Lambeth Events Safety Advisory Group (LESAG) remember this is only for large and major events, so smaller ones normally fast track through this process.
• Stage 3 – Local Community & Ward Councillor Engagement. We want to make sure as many local people as possible are aware of you event and we give them around 3 weeks to comment or raise any concerns to us on an event application. For small and medium low risk events this is a notification to local community groups & ward councillors of the event taking place via our calendar.
• Stage 4 – Final Assessment and Decision to grant the Park or Street – Event Permit. Once you have your permit we help to support and promote the event in a variety of ways on our Events website, through our social media networks and community links.

Event Application Timescales
Aligned with the above protocols are also event guidelines and timescales of which all event applicants have to adhere to for their applications. These are highlighted in our events guide and our events application forms. For major events (20,000+ people) the application must be made at least twelve months in advance.

The current statuses for the event applications for both Lovebox and Field Day are that they are at Stage 3 Community Engagement until 21 January. Following this we will be collating the feedback, comments and responses to the events service for inclusion within the Event Proformas so that the lead Cabinet Member and Director can make their assessment and final decision on granting permits for these two events. I understand that you have already sent back the feedback to this from the BPCP and this will be included for the assessment.

Stage 3   Local community and ward councillor engagement for large or major events is a period of time set aside for the Lambeth event staff and the Large or Major event applicant to engage with the BPCP and local ward councillors. We do this formally using an event proforma document which is then circulated to the BPCP for input and we also look to set up a time that is convenient for the BPCP and the event organisers to do a formal presentation on the event. (This is not always possible – Ed)

It is only once a positive decision has been made by the Lead Cabinet Member and the Director of Environment to grant a Park Event Permit that the applicants will go on to apply for a premises licence. If the decision is to refuse the permit then there would of course be no point in the applicants trying to obtain a premises licence. If the permit was granted, however, the licence applications would only go to the Licensing Sub-Committee in the event of relevant representations being made against the applications. If no representations were made against the application then they must be granted by officers under delegated powers. I would add, for the sake of completeness, that there might also need to be an application for planning permission for all Brockwell Park events, which would be considered separately.

Only when all the licences and permissions are in place and we have a final acceptance from the LESAG members do we actually issue the permit to use the park as we continue to follow our process right up to the events. This process can be very lengthy for large and major events.

Events, deadline for consultation extended to 21st Jan

Received from Lee Fiorentino, director of Events and applies to both applications, LoveBox and Field Day

This is formal notification that the event pro-forma Stage 3 community engagement process for the Field Day event, which started on the 20 November 2017 was for 3 weeks and scheduled to end on the 11 December 2017. However to take in to account the increased interest in this event and the holiday period we decided to extend the community engagement from 3 weeks to 9 weeks which means the final deadline date for responding back with comments to the Events team will be 21 January 2018. Please can you ensure you have sent all your feedback, comments and any concerns to us by Sunday 21 January 2018. The final Stage 4 decision to grant the Park Event Permit will be decided week commencing the 29 January 2018.

Lambeth Events say that once the Park Permit decisions are made at the end of January the Event Licence applications for LoveBox and Field Day will be submitted, probably during the first week in February. There follows a 28 day formal consultation period during which the views of the statutory consultees (e.g. Police) will be considered. There is no reason why the general public may not make their own submissions before the deadline at the beginning of March. All the submissions have to be put before the Licensing Committee. The form can be accessed here

Your submission has to address Lambeth’s Licensing objectives:

1. Prevention of crime and disorder

2. Public safety

3. Prevention of public nuisance

4. Protection of children from harm (moral protection, that is)

 

Opposition to the events proposals for Brockwell Park in 2018

Lambeth councillors and officers have been taken by surprise by the strength of community feeling about the proposals. They will continue to take comments from the public during January. If people still wish to send in their views they can be submitted to the event operations team; events@lambeth.gov.uk; to the Cabinet member: swinifred@lambeth.gov.uk or other local councillors.

BPCP is still sending on any comments received at our email address brockwellparkcommunitypartners@gmail.com, although not those which have  already been sent direct to councillors or Lambeth Events.

A public meeting has been called for 18th January, 7.30pm at the Herne Hill Baptist Church for local residents to put their views to and question LoveBox and Field Day organisers.  More details at Brixton Buzz.